The purpose of this pamphlet is to provide practical, cost-effective solutions concerning access to hotel services and facilities by your guests who are blind, deaf-blind, or visually impaired, as required by the Americans with Disabilities Act (ADA). The ADA is a civil rights law signed by President Bush on July 26, 1990. The law mandates that individuals with disabilities shall have access to jobs, public accommodations, government services, public
transportation, telecommunications--in short, participation in, and full access to, all aspects of society. Businesses that are designated as public accommodations by Title III of the ADA must eliminate barriers which impede access to their goods and services by persons with disabilities. Access can be accomplished by a variety of means including: making reasonable modifications in policies and procedures, removing architectural or structural communication barriers (such as conventional signage which cannot be read by persons who are blind or visually impaired) where it is readily achievable to do so, or providing auxiliary aids or services (such as reading a hotel bill to a guest
who is blind) if it is not an undue burden and does not fundamentally alter the nature of the goods and services offered.

The law is designed to be flexible in the way in which businesses can comply with ADA requirements. It further recognizes that certain accommodations may be
too costly or burdensome for a particular business. In such cases, the law requires you to employ alternative methods that are not so costly and burdensome in order to afford as much access as possible to your goods or services by blind or visually impaired customers.

Although the information contained in this pamphlet is targeted to hotel managers and service employees, many of the issues addressed (such as access to written documents, handling of currency, sighted guide technique, and awareness of, and sensitivity to, the needs of persons who are blind, deaf-blind, or visually impaired) are also applicable to other places of public accommodation
such as retail establishments, restaurants, and museums.

Accessibility checklists provided in this pamphlet illustrate methods of eliminating communications barriers impeding access to your guest services and
facilities. Most of the accommodations listed on the checklist will involve minimal cost. The checklists and explanatory notes contained in this pamphlet
illustrate and suggest some methods to remove or minimize barriers faced by your customers who are blind, deaf-blind, or visually impaired. For example, use of a passcard-type room key may be difficult for a guest who is blind, deaf-blind, or visually impaired. It is often not possible to determine by touch which way to place the card into the locking mechanism. One solution to this problem might be to place a small piece of tape on the card running in the same direction as the visual arrow. Removal of many communication barriers will require nothing more
than a bit of creative, "common sense" problem solving or will involve a simple courtesy such as, "How can I be of assistance to you, Mr. Jones?" This simple
question can be one of the most powerful ADA compliance tools. For additional solutions not covered in this pamphlet or for more detailed information than we
provide here, consult with the advocacy organizations and federal departments or agencies indicated in the resource list. You may wish to obtain copies of the
Title III regulations and the Title III Technical Assistance Manual published by the U.S. Department of Justice.

NOTE: [In addition to its obligations as a place of public accommodation, your hotel may also have certain obligations regarding employment covered by Title I of the ADA. If you need information regarding employment, you should contact the Equal Employment Opportunity Commission (EEOC) for further information. The EEOC's address and phone number are contained in the resource
list.]

As a hotel manager or service employee, you know that good customer service means greater profit for your hotel. A small investment in training time and
money to achieve accessibility will pay great dividends in terms of new and repeat business and public exposure as an establishment which fully complies with, or even exceeds, ADA access requirements. Although most of the solutions
suggested in these pages should involve little difficulty or expense, it is impossible to predict whether a given accommodation will represent an undue
burden in every instance or whether a structural modification is readily achievable in light of your particular circumstances.

The ADA was designed to ensure that individuals with disabilities are afforded an equal opportunity to participate in all aspects of society. At the
same time, the law recognizes the burdens placed on business to provide such access, and further recognizes that what is an undue burden for a multinational
hotel chain is different from what constitutes an undue burden for a ten-room, owner-occupied inn.

Although this pamphlet will help you to examine all of your guest services and facilities to identify barriers faced by your guests who are blind, deaf-blind, or visually impaired and will also suggest solutions to many barriers along the way, your customers will often suggest the most important solutions. In October of 1991 the American Foundation for the Blind opened an ADA hotline, funded by the U.S. Department of Justice, to answer questions on
implementation of Titles II and III of the ADA. The information discussed in this pamphlet is illustrative of the information sought by numerous hotels,
consultants and consumers who called the hotline. A brochure cannot address every barrier to access in your hotel. Rather, through a series of checklists,
we will guide you through a process of examining your facilities and services,
identifying possible barriers to access faced by guests who are blind,
deaf-blind, or visually impaired, and finally, recommending a method to identify
possible solutions to these barriers. Not every guest will experience each
barrier addressed in the checklists, and you may find solutions which are not
listed on the checklists. In addition, some guests will not want or need a particular accommodation. Accordingly, if you are in doubt about what accommodation is needed by a guest who is blind, deaf-blind, or visually
impaired, simply ask. If the response is a refusal of assistance or a particular accommodation, the law requires you to respect your guest's wishes in this
regard. If your guest requests assistance, let him or her guide you in the most
effective way of responding to his or her request.

If you have already given some thought to access, examined your services and
facilities, identified barriers, and implemented solutions, you will be well on
your way to complying with the ADA, and, more important, your guests will
probably want to come back to your hotel.

Is my hotel covered by Title III of the ADA?

Your establishment is covered by the ADA as a place of public accommodation
if it is a private entity and is a place of lodging (including inns, hotels, and
motels). The ADA does not cover owner-occupied establishments renting five or
fewer rooms.

You keep referring to guests who are "blind, deaf-blind, or visually
impaired." What do you mean by this? Why this distinction?

When most people think of a person who is blind, they usually make three assumptions:

that the person will be totally blind,

that the person will use braille, and

that the person will travel with a cane or dog.

Your hotel guest may fit all these assumptions. However, these assumptions are not true for most individuals who are "blind." Roughly three-quarters of the population who are "blind" are not totally blind, i.e., they have some residual vision. Similarly, most persons who are deaf-blind have some usable vision. Some persons who are
blind, deaf-blind or visually impaired may use braille, some may use a cane, others may use a dog, and still others may not use braille or a mobility aid at all. Thus, your guest who is visually impaired may be a person with a hidden disability. The tremendous variability in how persons who are visually impaired respond to their vision loss depends on how differently various eye conditions influence the affected person's vision. For example, some individuals who are
visually impaired can see primarily in the periphery of their visual field, as if the center of their vision were blocked. Others can see only in the central portion of their visual field, as if they were looking through a tunnel. Still others may see somewhat in all sectors of their visual field, but what they see is distorted or blurred in some way. This variability obviously has implications for how the person in question uses his or her remaining vision.

Many persons who are visually impaired function best under specific lighting conditions. Most often, direct lighting that does not produce glare or shadows makes it easier for such persons to perform tasks. It is important to realize that too much light produced from reflective interior surfaces, large windowed walls, spotlights, or certain paper coatings may create problems due to glare. Finally, many people who are visually impaired may use a hand-held magnifier or may use more sophisticated visual aids.

What does this all mean to the hotel manager or service employee?

Do not make assumptions about the extent of your guest's visual acuity, and be guided by his or her request for assistance.

In general, what must a hotel do for guests who are blind, deaf-blind, or visually impaired to comply with Title III of the ADA?

Generally speaking, guests who are blind, deaf-blind, or visually impaired may not be denied full and equal enjoyment of the goods, services, facilities,
privileges, advantages, or accommodations provided by your establishment. In other words, public accommodations such as hotels must ensure that guests who are blind, deaf-blind, or visually impaired have an equal opportunity to
participate in and benefit from all of the goods and services provided by your hotel. This may mean that you must modify your policies or procedures, eliminate
discriminatory eligibility criteria, provide auxiliary aids and services, and, if readily achievable, take steps to remove structural communication barriers in
existing facilities. Auxiliary aids and services include, but are not limited to, readers, taped texts, braille materials, acquisition or modification of
equipment, and other similar actions. Thus, you may be asked by a guest who is visually impaired for guide assistance or for assistance in reading her bill,
even though she may not use a dog guide or a cane. Similarly, a person who is visually impaired may request an additional lamp in his guest room, ask to be
seated in the most brightly lit section of your restaurant, or to be seated away from a large window area producing uncomfortable glare.

Okay, how do I tell whether my hotel's services and facilities are accessible to, and usable by, customers who are blind, deaf-blind, or visually
impaired?

Although not required by the ADA, a self-evaluation and a barrier removal plan are the most effective ways of determining how accessible your hotel is now and what steps are necessary to provide greater accessibility in the future. Start with the barriers-elimination checklists. Each section of the checklist applies to a particular function in your hotel such as front desk services, gift shop/retail, food and beverage services, and so on. Each checklist section was designed as a stand-alone module which you can photocopy for use by the
appropriate function or department within your hotel. The explanatory notes section is designed for use with all checklists.

The self-evaluation begins by identifying barriers to effective communication within each function of your hotel; determine how the communication barriers are
currently being addressed, if at all, and then identify the range of solutions available which will eliminate or minimize these barriers to communication. Is
your current response adequate, or must you do more? Which solutions are effective, least expensive, or easiest to implement?

The ADA permits you to choose alternate methods of eliminating barriers to effective communication. While consultation with persons with disabilities,
including groups or organizations that represent them, is strongly encouraged,
you may make the decision about what measures to take provided that the method
chosen results in effective communication.

Once barriers are identified and solutions determined, you should then develop a plan for implementation. Thus, if it is determined that employee or staff training curricula must be modified, when will this be accomplished?
Similarly, if funds must be expended to remove a structural communication barrier, e.g., by replacing conventional signage with raised character and braille signage where necessary, when will this be done?

With respect to architectural and structural communication barriers in
existing facilities, the U.S. Department of Justice's regulations permit you to
establish priorities for the removal of such barriers.

If your time frames are reasonable and solutions effective, your good faith effort to comply with the ADA will be an important factor in your favor in any
proceeding to adjudicate a complaint against you. If you need help with the process of self-evaluation and development of an implementation plan, it is a
good idea to contact one or more of the advocacy organizations or federal departments or agencies appearing in the resource list of this pamphlet. Assistance from organizations of and for persons who are blind as well as qualified individuals who are blind, deaf-blind, or visually impaired can be an invaluable resource in your efforts to comply with the ADA.

__ acquiring equipment, such as tactile and large print thermostat controls, talking/large-print clocks, and Brailtalk alphabet for persons who are deaf-blind

__ controlling environmental white noise, e.g., white noise created by velocity of water in fountains may mask environmental sound clues used by persons who are blind or visually impaired as an aid to orientation and mobility

__ providing adequate lighting and control of glare in common areas [14]

__ awareness of how to obtain a tactile interpreter if required for a guest who is deaf-blind [13]

__ awareness of how to obtain a reader if required for a guest who is blind or visually impaired

__ awareness of how to obtain meeting materials, e.g., agendas, in braille, tape, large print, or electronic computer file formats

__ providing priority seating upon request, e.g., in area in meeting room where lighting is more adequate or where a person who is visually impaired may have a better view of the podium

Explanatory Notes

[1] Identifying personnel. Staff should initiate an
introduction to a guest who is blind, deaf-blind, or visually impaired and should always identify themselves by name and function. Name badges and uniforms may not be seen by a guest who is visually impaired.

[2] Reviewing documents. Staff should read fully,
upon request, and provide assistance, if necessary, in completing registration
folios, hotel bills, service request forms, menus, and other documents. You may
find it more helpful to your guest to provide frequently used documents such as menus or important documents such as contracts in braille, tape, or large print. When reading a menu, personnel should first read broad categories of items and allow the guest to choose which categories should be fully read. For example, "Would you like me to read the list of appetizers?"

[3] Counting and identifying currency; credit cards;
signatures. When handing currency to a guest, bills should be individually
identified and counted. A person who is blind or visually impaired usually identifies currency by folding it in different ways and/or by placing denominations in separate locations in a wallet or purse. Identifying coins is usually not a problem because of their varying sizes and milled edges. Credit cards should be handed to guests after imprint, not simply laid on a counter or table. A piece of cardboard or a plastic or metal signature template can be used to indicate where a signature is required. Place cardboard edge horizontally below line or orient opening of signature template where signature is required.

[4] Sighted guide technique and mobility aids. Staff should not touch or remove mobility canes unless requested to do so and should not interfere with dog guides. Identify yourself and offer guide assistance if it appears to be needed. If assistance is accepted, offer your arm to the guest.
The guest will lightly hold your arm directly above the elbow. Don't pull or push the guest or hold his arm. Relax and walk at a comfortable, normal pace. Allow the guest to walk a step or two behind you, and indicate changes in terrain, such as stairs, narrow spaces, and escalators, by hesitating briefly as you approach them and explaining what you are about to do. When seating the guest, ask if you may show him or her the back of the chair. If the response is yes, simply place the guest's hand on the chair back. When it is time for you to leave, indicate that you are leaving his or her presence.

[5] Verbalizing directions. Be specific. Be sure to
use right and left as they apply to the person who is blind. What is on your right is on the left of a person facing you. Indicate number of blocks to the
department store and whether one proceeds right or left when exiting the hotel. Provide the address and indicate such things as the number of doorways from the
corner and distance. Simply saying, "The department store is about six blocks down in that direction" is ineffective. Similarly, be specific about directions to rooms within the hotel, e.g., "To find the Monroe Room, go to the end of this corridor, turn left, and it's the fifth room on your right."

[6] Using disability-sensitive language and etiquette. Using words such as blind, visually impaired, seeing, looking,
watching television are acceptable words in conversation. Similarly, using descriptive language, including references to color, patterns, and the like, is appropriate. When referring to guests with disabilities, refer to the person
first, then the disability, e.g., refer to the guest in 439 who is blind, rather than the blind man in 439.

[7] Communicating with persons who are deaf-blind. Most persons who are deaf-blind communicate using finger spelling, printing letters in the palm, or tactile American Sign Language. The guest who is deaf-blind may also use braille or, if he or she has some residual vision, large print. In most cases, the person who is deaf-blind will inform you, either through speech, writing, a companion, or use of preprinted "help card" messages of his or her preferred mode of communication. Once communication has begun, be sure to ask frequently whether your communication is understood. The ADA
requires the provision of interpreters only if the communication is particularly complicated, e.g., involving important financial or healthcare decisions. If a
tactile interpreter is required, you may be able to find a tactile interpreter
through the Registry of Interpreters for the Deaf listed in the Yellow Pages or through a local sign language or deaf service agency. If the person who is
deaf-blind is traveling with a person who hears, it is a good idea to offer them adjoining rooms or offer to provide the hearing person with a duplicate key. In addition, staff should be aware of the universal sign for an emergency situation, i.e., drawing the letter X on the back of the person who is deaf-blind with the fingertips. Use of an aid like the Brailtalk tactile communicator can also facilitate communication. This is an inexpensive plastic
device that contains braille and raised character alphabet and numerals. For many people who are deaf-blind, communication can be accomplished using this device by simply pointing the finger to the appropriate braille or raised letters or numerals. In addition, some persons who are deaf-blind may use combination braille and print "help cards" containing basic messages.

[8] Dog guides. The ADA requires admission of service animals to hotels unless a fundamental alteration in the nature of the
goods and services provided would result or safe operation of the hotel is jeopardized. The dog guide should always remain under control by its owner. In addition, care and supervision of the animal is the responsibility of the guest. Staff should not pet, feed, or otherwise distract dog guides from their work. Although the ADA does not require you to provide a dog guide relief area, it would be helpful to your guest if you can provide some suggestions in this regard.

[9] Food service assistance. Such assistance could
include cutting meat on request. For buffet service, assistance could include identifying and-or serving food on buffet table. For table service, the waiter
should explain arrangement of the tableware and announce the placement of food and beverage items as they are being served. One way to assist the guest would be to describe the location of the food or beverage using the face of a clock. For example, "Your meat is at 6 o'clock and your vegetables are at 3 o'clock."

[10] TDDs for guests who are deaf-blind. Subject to the undue burden defense, a hotel permitting a guest to make outgoing calls on
"more than an incidental, convenience basis" must, upon request, provide a TDD (telecommunications device for the deaf) for the guest's use. Accordingly, a hotel may be required to provide a braille-output TDD to a guest who is deaf-blind.

[12] Accessible signage and other ADAAG requirements. The ADA Accessibility Guidelines (ADAAG), which is available as an appendix to the Justice Department's Title III regulations, contains several provisions concerning accessibility: braille, raised characters, contrast, Serif, and character height. In addition, the ADAAG contains provisions regarding braille and raised character elevator controls, audible
direction indicators, floor designations on elevator hoistways, and protruding objects. The ADAAG also contains provisions regarding stairs and handrails. These ADAAG requirements must generally be incorporated into new construction and must be incorporated when facilities are being altered. Items such as raised character and braille elevator controls are usually required to be installed in existing facilities, because they involve little difficulty or expense and are generally considered to be readily achievable.

[13] Tactile interpreters. Subject to an undue
burden defense, use of a tactile interpreter or notetaker may be the only effective means of providing communication to a person who is deaf-blind attending a meeting or conference. A notetaker could transcribe a summary of
verbal communication to keep a participant who is blind informed of the proceedings.

[14] These items are not reflected in the ADAAG, but are listed here because awareness of the barrier that they represent to persons who are blind or visually impaired will aid architects and designers in the development of appropriate standards. For example, although inadequate lighting, glare, and interference from masking sounds present significant barriers to access for many persons who are visually impaired, the ADAAG currently do not contain standards relative to ambient lighting, glare control, or white noise.

Resources

Government Agencies

You can obtain further information, copies of the ADA regulations, and technical assistance manuals from the following government departments or agencies:

This document provides general information to promote voluntary compliance with the Americans with Disabilities Act (ADA). It was prepared under a grant from the U.S. Department of Justice. While the Department's Public Access Section has reviewed its contents, any opinions or interpretations in this document are those of the American Foundation for the Blind and do not necessarily reflect the views of the Department of Justice. The ADA itself and the Department's ADA regulations should be consulted for further, more specific guidance.

The Americans with Disabilities Act Communications Accommodations Project was a joint program of the American Foundation for the Blind and the National Center for Law and Deafness.

Resource section updated by the American Foundation for the Blind
May 2006